Business Owners

Business Valuation for Tax Planning and Succession: Value Is Not the Same as Price, Basis, or Book Equity

The practitioner should identify why value is needed, the valuation date and interest, distinguish enterprise from equity value, normalize earnings carefully, and use qualified valuation professionals when a formal appraisal is required.

Value is not the same as price, basis or book equity. Tax planning uses valuation for gifts, estates, redemptions, charitable transfers, buy-sell arrangements, compensation, litigation support and business exits—often with different standards and dates.

Define the purpose and standard of value

Fair market value for federal transfer tax has a specific willing-buyer/willing-seller framework. A strategic sale price, investment value or formula price in an agreement may answer a different question.

Normalize the financial statements carefully

Owner compensation, related-party rent, discretionary expenses, one-time events and nonoperating assets can affect normalized earnings. Adjustments should be documented and supportable, not selected merely to reach a preferred value.

Use the appropriate valuation approaches

Income, market and asset approaches each fit different facts. The appraiser should explain the method, assumptions, capitalization/discount rates and weighting rather than presenting a single unexplained number.

Discounts require facts

Lack-of-control and lack-of-marketability discounts can be appropriate in some transfer-tax settings, but they are not automatic percentages. Ownership rights, restrictions and market evidence matter.

Keep valuation date and tax purpose aligned

A business can change rapidly. The value used for a gift, estate, redemption, charitable contribution or compensation analysis should match the relevant valuation date and statutory purpose.

Planning takeaway

Value is a conclusion tied to purpose, date and evidence.

Use qualified valuation professionals when material, reconcile the valuation to tax reporting and preserve the assumptions that connect the financial facts to the conclusion.

Authorities & references

Primary authority to review

  • Treas. Reg. §§20.2031-1 and 25.2512-1
  • Revenue Ruling 59-60 and subsequent valuation authority
  • IRC §409A where compensation valuation is relevant
  • Specialist secondary review: Ed Cotney business valuation materials, reconciled to primary authority

Evergreen article · Verify current-year indexed amounts and current jurisdiction-specific rules · Last reviewed September 2026